M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

Section 9(1)(vii) of the Act. 10. For the aforesaid reasons, we hold that the view taken by the Bombay High Court that the transaction charges paid to the Bombay Stock Exchange by its members are for 'technical services' rendered is not an appropriate view. Such charges, really, are in the nature of payments made for facilities provided

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

Section 9(1)(vii) of the Act. 10. For the aforesaid reasons, we hold that the view taken by the Bombay High Court that the transaction charges paid to the Bombay Stock Exchange by its members are for 'technical services' rendered is not an appropriate view. Such charges, really, are in the nature of payments made for facilities provided

ARUN DURAISWAMY,MYSORE, KARNATAKA vs. ITO, INTL. TAXATION WARD 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

90,654/- proceedings were initiated by an Income Tax (excluding Authority who had no jurisdiction over the interest) Appellant. 3. Without prejudice to ground no 2 and assuming without admitting that the proceedings were validly initiated, the order of Same as above the Ld. AO and the order of the Ld DRP under whose directions the impugned assessment order

M/S. BANGALORE PHARMACEUTICAL AND RESEARCH LABORATORY PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2018-19

90,669. The return was processed by CPC and intimation u/.s 143(1) was issued on 04.10.2019 determining returned loss at Rs.64,20,173 (Rs.3,13,183 lesser than returned loss) on account of disallowance of Rs.3,13,183 u/s. 36(1)(va) for delayed deposit of employees contribution to Provident Fund (PF) and ESI. The assessee filed rectification application

M/S. SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, UDUPI

In the result, grounds 6 and 9 are allowed for statistical purposes

Bench: Shri George George K, Jm & Ms.Padmavathy S, Jm

90,65,332 u/s 36(1)(viia) of the Act being the amount eligible as calculated under the section in its original return. During the assessment proceedings, the assessee-bank made a revised claim of Rs.1494,99,64,784 u/s 36(1)(viia) of the Act. The assessee calculated deduction based on Aggregate Average Rural Advances (AAA) computed

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

MR. VIKRAM DHONDU RAO, ,BANGALORE vs. DCIT, CIRCLE-4(1)(1), BANGALORE

In the result, appeal filed by the assessee in ITA No

Section 143(1) of the Act.\n5. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in confirming the denial of the relief u/s 90 of the Act amounting to Rs.15,20,710/-.\n6. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in concurring with the finding

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

1,07,90,215/- under Section 201(1A) of the Act. 2.1. During the assessment year 2012-13 in ITA no.1151, the assessee created aggregate provision of Rs. 49,16,35,934/- towards various expenses. While computing the total income assessable for the assessment year 2012-13, the assessee suo moto disallowed the entire provision so created under Sections

DELL INDIA P LTD,BANGALORE vs. INCOME TAX OFFICER(TDS), LTU, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

1,07,90,215/- under Section 201(1A) of the Act. 2.1. During the assessment year 2012-13 in ITA no.1151, the assessee created aggregate provision of Rs. 49,16,35,934/- towards various expenses. While computing the total income assessable for the assessment year 2012-13, the assessee suo moto disallowed the entire provision so created under Sections

INCOME TAX OFFICER, BANGALORE vs. M/S.DELL INDIA PVT.LTD.,, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

1,07,90,215/- under Section 201(1A) of the Act. 2.1. During the assessment year 2012-13 in ITA no.1151, the assessee created aggregate provision of Rs. 49,16,35,934/- towards various expenses. While computing the total income assessable for the assessment year 2012-13, the assessee suo moto disallowed the entire provision so created under Sections

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

Section\n153D. It is not an exercise dealing with a immaterial matter which\ncould be corrected by taking recourse to Section 292B of the Act.\n16. We are not inclined to interdict the order of the Tribunal.\n17. Accordingly, the appeal is closed.\n6.5 The above view taken by the Hon’ble Delhi High Court in the case of PCIT

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

TDS on payments made by the appellant to M/s. Google Ireland Ltd., as the AO characterized the payment made by the appellant to M/s. Google Ireland Ltd., as royalty. Under the Adword Program distribution agreement, the agreement was entered into between GIPL and Google Ireland Ltd., (hereinafter called as “GIL). The GIPL was granted the marketing and distribution rights

ARIBA TECHNOLOGIES INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

90 days of agreed credit period for each and every invoice and applying interest rate as SBI-PLR i.e. 13.27%. The TPO calculated the ALP of interest on outstanding receivable at Rs. 3,14,25,633/- only. Accordingly, the TPO proposed the final TP adjustment of ₹3,14,25,633/-. 13. Being aggrieved the assessee preferred to file objection before

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

90 as well as limitation, common order was passed by the authority and there was no prohibition in law for passing a common order for the common question of law and there is no difference in facts in all the years. He had also drawn our attention to section 143(1) and section 201 and submitted ITA Nos.1215

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

90 as well as limitation, common order was passed by the authority and there was no prohibition in law for passing a common order for the common question of law and there is no difference in facts in all the years. He had also drawn our attention to section 143(1) and section 201 and submitted ITA Nos.1215

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

90 as well as limitation, common order was passed by the authority and there was no prohibition in law for passing a common order for the common question of law and there is no difference in facts in all the years. He had also drawn our attention to section 143(1) and section 201 and submitted ITA Nos.1215

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

90 as well as limitation, common order was passed by the authority and there was no prohibition in law for passing a common order for the common question of law and there is no difference in facts in all the years. He had also drawn our attention to section 143(1) and section 201 and submitted ITA Nos.1215

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

90 as well as limitation, common order was passed by the authority and there was no prohibition in law for passing a common order for the common question of law and there is no difference in facts in all the years. He had also drawn our attention to section 143(1) and section 201 and submitted ITA Nos.1215